BP Amoco Texas City Business Unit - Executive Summary
DESCRIPTION OF THE STATIONARY SOURCE AND REGULATED SUBSTANCES |
The BP Amoco Texas City Refinery, located in Galveston County, Texas processes 437 thousand barrels of crude oil per day to produce petroleum products such as gasoline, jet fuel, diesel fuel, home heating oil, petroleum coke, chemical feedstocks, etc. The refinery, the most complex in the world, contains twenty-two processes covered under the Risk Management Program (RMP) rule; all of these processes are classified as Program 3. All covered processes contain regulated flammable mixtures held above the threshold quantity of 10,000 pounds. The flammable mixtures contain various regulated substances such as, but not limited to, methane, propane, butane, and pentane. In addition, ten processes contain chlorine above its threshold quantity of 2,500 pounds; one process contains hydrogen fluoride above its 1,000 pound threshold quantity; one process contains ammonia above its threshold quantity of 10,000 pounds; and one proce
ss contains hydrogen sulfide above its 10,000 pound threshold quantity.
ACCIDENTAL RELEASE PREVENTION AND RESPONSE POLICIES
The BP Amoco Texas City Refinery has a long-standing commitment to worker and public safety. This commitment is demonstrated by the resources invested in accident prevention, such as training personnel and considering safety in the design, installation, operation, and maintenance of our processes. Our refinery adheres to federal and state regulations, industry standards and practices, Amoco process safety policies and guidelines, and best practices that have been developed based on company and industry experience over the years. Some of the resource material such as the Amoco Process Safety Booklets, the Amoco Refining Business Group Process Safety Standards and Guideline Manual, the Amoco Refining Business Group Implementation Guidelines for OSHA 1910.119, the Amoco Recommended Good Practices Manuals, and the Amoco Corporate Engineering Specifications, the Tex
as City Refinery Process Safety Guidelines, the Texas City Health, Safety and Environmental Policies, and the Texas City Contractor Safety Program will be discussed in more detail in subsequent sections. Our policy is to implement reasonable controls to prevent foreseeable releases of regulated substances. However, if a release does occur, our trained personnel will respond to control and contain the release.
HAZARD ASSESSMENT RESULTS
The RMP rule requires facilities to calculate worst case and alternative release scenarios for each regulated substance on-site. The purpose in calculating these types of scenarios is to encourage community dialogue on chemical accident prevention and risk reduction. The BP Amoco Texas City Refinery has performed these calculations using the methodology given in the EPAs Offsite Consequence Analysis Guidance Document. The results of these calculations have been provided to the EPA and to the Texas City/La Marque/Hitchcock LEPC, and have been shared
with members of the local community.
The likelihood of these types of events is extremely remote. The BP Amoco Texas City Refinery employs many layers of protection to reduce risk and to prevent chemical accidents.
Flammable Worst Case Scenario
The worst-case scenario for a flammable substance would be a vapor cloud explosion resulting from an instantaneous failure of a pentane storage vessel. In calculating the potential impact zone, no credit was taken for administrative controls or mitigation systems. The impact zone from such an event would extend beyond the boundaries of the refinery.
Toxic Worst Case Scenario
The worst-case scenario for toxic substances would be a plume of hydrogen fluoride (HF) from an instantaneous failure of an HF storage vessel. In calculating the potential impact zone, no credit was taken for administrative controls or mitigation systems. The impact zone from such an event would extend beyond the boundaries of the refinery.
Flammable Alternate Release S
The alternative release scenario for a flammable substance is a vapor cloud explosion resulting from a release of propane from a two inch piping leak. In calculating the potential impact zone, no credit was taken for administrative controls or mitigation systems. The impact zone from such an event would extend beyond the boundaries of the refinery.
Toxic Alternate Release Scenarios
The alternate release scenario for hydrogen fluoride is a plume resulting from a pump seal leak. In calculating the potential impact zone, credit was taken for an automatic water spray mitigation system, and a rapid isolation and deinventory system. The impact zone from such an event would extend beyond the boundaries of the refinery.
The alternate release scenario for chlorine is a plume resulting from a 1/4 tubing break. In calculating the potential impact zone, no credit was taken for administrative controls or mitigation systems. The impact zone from such an event would extend beyond the b
oundaries of the refinery.
The alternate release scenario for hydrogen sulfide is a plume resulting from a two inch diameter piping leak. In calculating the potential impact zone, no credit was taken for administrative controls or mitigation systems. The impact zone from such an event would extend beyond the boundaries of the refinery.
The alternate release scenario for ammonia is a plume resulting from a two inch diameter piping leak. In calculating the potential impact zone, no credit was taken for administrative controls or mitigation systems. The impact zone from such an event would extend beyond the boundaries of the refinery.
GENERAL ACCIDENTAL RELEASE PREVENTION PROGRAM STEPS
Following is a summary of the general accident prevention programs in place at the BP Amoco Texas City Refinery. Because processes at the refinery regulated by the EPA RMP regulation are also subject to the OSHA PSM standard, this summary addresses each of the OSHA PSM elements and describes the manageme
nt system in place to implement the accident prevention program.
The BP Amoco Texas City Refinery encourages employees to participate in all facets of process safety management and accident prevention. Examples of employee participation range from updating and compiling technical documents and chemical information to participating as a member of a process hazard analysis (PHA) team. Employees have access to all information created as part of the refinery accident prevention program. Specific ways that employees can be involved in the accident prevention program are documented in an employee participation plan that is maintained at the refinery.
Process Safety Information
The BP Amoco Texas City Refinery keeps a variety of technical documents that are used to help maintain safe operation of the processes. These documents address chemical properties and associated hazards, limits for key process parameters and specific chemical inventories, and equipment design
basis/configuration information. Specific departments within the refinery are assigned responsibility for maintaining up-to-date process safety information.
Chemical-specific information, including exposure hazards, emergency response measures, and exposure treatment is provided in material safety data sheets (MSDSs). This information is supplemented by documents that specifically address known corrosion concerns and known hazards associated with the inadvertent mixing of chemicals. The refinery has also documented the safe operating limits for specific, safety-related process parameters (e.g., temperature, level, composition). The refinery ensures that the process is maintained within these limits using process controls and monitoring instruments, highly trained personnel, and protective instrument systems (e.g., automated shutdown systems).
The refinery also maintains technical documents that provide information about the design and construction of process equipment. This infor
mation includes the materials of construction, the design pressure and temperature ratings, the electrical rating of equipment, the piping and instrument drawings, etc. This information, in combination with written procedures and trained personnel, provides a basis for establishing inspection and maintenance activities, as well as for evaluating proposed process and facility changes to ensure that safety features in the process are not compromised.
Process Hazard Analysis
The BP Amoco Texas City Refinery has a comprehensive program to help ensure that hazards associated with the various processes are identified and controlled. Within this program, each process is systematically examined to identify hazards and ensure that adequate controls are in place to manage these hazards.
The BP Amoco Texas City Refinery primarily uses the hazard and operability (HAZOP) analysis technique to perform the process hazards analysis (PHA). HAZOP analysis is recognized as one of the most systematic a
nd thorough hazard evaluation techniques. The analyses are conducted using a team of people who have operating and maintenance experience as well as engineering expertise. The PHA team identifies and evaluates hazards of the process as well as accident prevention and mitigation measures, and makes suggestions for additional prevention and/or mitigation measures when the PHA team believes such measures are necessary.
The PHA team findings are forwarded to management for resolution. Implementation of mitigation options in response to PHA findings is based on a relative risk ranking assigned by the PHA team. This ranking helps ensure that potential accident scenarios assigned the highest risk receive prompt attention. All approved mitigation options being implemented in response to PHA team findings are tracked until they are complete. The final resolution of each finding is documented and retained.
To help ensure that the process controls and/or process hazards do not eventually de
viate significantly from the original design safety features, the BP Amoco Texas City Refinery periodically updates and revalidates the PHA results. These periodic reviews are conducted at least every 5 years and will be conducted at this frequency until the process is no longer operating. The results and findings from these updates are documented and tracked. Once again, the team findings are forwarded to management for consideration and the final resolution of the findings is documented and retained.
The BP Amoco Texas City Refinery maintains written procedures that address various modes of process operations, such as (1) unit startup, (2) normal operations, (3) temporary operations, (4) emergency shutdown, (5) normal shutdown, and (6) initial startup of a new process. These procedures can be used as a reference by experienced operators, and provide a basis for consistent training of new operators. These procedures are periodically reviewed and revised as ne
cessary to reflect changes made through the management of change process. These procedures are certified annually as current and accurate.
To complement the written procedures for process operations, the BP Amoco Texas City Refinery has implemented a comprehensive training program for all employees involved in operating a process. New employees receive basic training in refinery operations. After successfully completing this training, a new operator is paired with a senior operator to learn process-specific duties and tasks. After operators demonstrate (e.g., through tests, skills demonstration) adequate knowledge to perform the duties and tasks in a safe manner on their own, they can work independently. In addition, all operators periodically receive refresher training on the operating procedures to ensure that their skills and knowledge are maintained at an acceptable level. This refresher training is conducted at least every 3 years. Initial and refresher training is
documented for each operator, including the means used to verify that the operator understood the training.
The BP Amoco Texas City Refinery uses contractors to supplement its workforce during periods of increased maintenance or construction activities. Because some contractors work on or near process equipment, the refinery has procedures in place to ensure that contractors (1) perform their work in a safe manner, (2) have the appropriate knowledge and skills, (3) are aware of the hazards in their workplace, (4) understand what they should do in the event of an emergency, (5) understand and follow site safety rules, and (6) inform refinery personnel of any hazards that they find during their work. This is accomplished by providing contractors with (1) a process overview, (2) information about safety and health hazards, (3) emergency response plan requirements, and (4) safe work practices prior to their beginning work. In addition, the BP Amoco Texas City Refinery eval
uates contractor safety programs and performance during the contractor selection process. Refinery personnel also monitor contractor performance periodically to ensure that contractors are fulfilling their safety obligations.
Pre-startup Safety Reviews
The BP Amoco Texas City Refinery conducts a pre-startup safety review (PSSR) for any new facility, or facility modification that requires a change in the process safety information. The purpose of the PSSR is to ensure that safety features, procedures, personnel, and the equipment are appropriately prepared for startup. This review provides one additional check to ensure construction is in accord with the design specifications, and that all supporting systems are operationally ready. The PSSR review team uses checklists to verify all aspects of readiness. A PSSR involves field verification of the construction, and serves a quality assurance function by requiring verification that accident prevention program requirements are properly
The BP Amoco Texas City Refinery has well-established practices and procedures to maintain the mechanical integrity of pressure vessels, piping systems, relief and vent systems, controls, pumps and compressors, and emergency shutdown systems in a safe operating condition. The basic aspects of the mechanical integrity program include: (1) conducting training, (2) developing written procedures and plans, (3) performing inspections and tests, (4) correcting identified deficiencies, and (5) applying quality assurance measures.
Maintenance personnel receive training on (1) an overview of the process, (2) safety and health hazards, (3) applicable maintenance procedures, (4) emergency response plans, and (5) applicable safe work practices to help ensure that they can perform their job in a safe manner. Written procedures help ensure that work is performed in a consistent manner, and provides a basis for training.
Periodic inspections and tests are performe
d to help ensure that equipment functions as intended, and to verify that equipment parameters are within acceptable limits (e.g., pressure vessel wall thickness). If a deficiency is identified, employees will remove the equipment from service and correct the deficiency, if possible. If it is not possible to immediately correct the deficiency, a team will review the deficiency and the use of the equipment, and determine what actions are necessary to ensure the continued safe operation of the equipment.
Another integral part of the mechanical integrity program is quality assurance. The BP Amoco Texas City Refinery incorporates quality assurance measures into equipment purchases and repairs. This helps ensure that new equipment is suitable for its intended use, and that proper materials and spare parts are used when repairs are made.
Safe Work Practices
The BP Amoco Texas City refinery has long-standing safe work practices to help ensure worker and process safety. Examples of thes
e include (1) control of the entry/presence/exit of support personnel, (2) a lockout procedure to ensure isolation of energy sources for equipment undergoing maintenance, (3) a procedure for safe removal of hazardous materials before process piping or equipment is opened, (4) a permit and procedure to control spark-producing activities (i.e., hot work), and (5) a permit and procedure to ensure that adequate precautions are in place before entry into a confined space. These procedures (and others), along with training of affected personnel, form a system to help ensure that operations and maintenance activities are performed safely.
Management of Change
The BP Amoco Texas City Refinery has a comprehensive management of change (MOC) system. This system requires that changes to items such as process equipment, chemicals, technology, and procedures are properly reviewed and authorized before being implemented. Changes are reviewed to (1) ensure that adequate controls are in place to man
age any new hazards and (2) verify that existing controls have not been compromised by the change. Affected chemical hazard information, process operating limits, and equipment information, as well as procedures, are updated to incorporate these changes. In addition, operating and maintenance personnel are provided any necessary training on the change. The MOC system requires that all documentation is updated, and training completed prior to commissioning the change.
The BP Amoco Texas City Refinery promptly investigates all incidents that resulted in, or reasonably could have resulted in, a fire/explosion, toxic gas release, major property damage, environmental loss, or personal injury. The goal of each investigation is to determine the contributing factors, and to develop corrective actions to prevent a recurrence of the incident or a similar incident. The investigation team documents its findings, develops proposals for corrective action, and forwards the
se results to refinery management for resolution. Corrective actions taken in response to the investigation team's findings and recommendations are tracked until they are complete. The final resolution of each finding or proposal is documented, and the investigation results are reviewed with all employees (including contractors) who could be affected by the findings. Incident investigation reports are retained for at least 5 years so that the reports can be reviewed during future PHAs and PHA revalidations.
To help ensure that the accident prevention program is functioning properly, the BP Amoco Texas City Refinery conducts periodic compliance audits to determine whether the procedures and practices required by the accident prevention program are being followed. Compliance audits are conducted at least every 3 years. Both hourly and management personnel participate as audit team members. The audit team develops findings that are forwarded to refinery managemen
t for resolution. Corrective actions taken in response to the audit team's findings are tracked until they are complete. The final resolution of each finding is documented, and the two most recent audit reports are retained.
CHEMICAL SPECIFIC PREVENTION STEPS
The processes at the BP Amoco Texas City Refinery have hazards that must be managed to ensure continued safe operation. The accident prevention program summarized above applies to all Program 3 processes at the refinery. Collectively, these prevention program activities help prevent potential accident scenarios that could be caused by (1) equipment failures or (2) human errors.
In addition to the accident prevention program activities, the BP Amoco Texas City Refinery has safety features on many units to help (1) contain/control a release, (2) quickly detect a release, and (3) reduce the consequences of a release (i.e., mitigate). The following types of safety features are used in various processes:
carbon detectors with alarms
2. Hydrogen fluoride detectors with alarms that activate automatic water-spray mitigation
3. Hydrogen sulfide detectors with alarms
1. Process relief valves that discharge to process flares to capture and incinerate episodic releases
2. Scrubbers to neutralize chemical releases
3. Valves to permit isolation of the process (manual and automated)
4. Automated shutdown systems for specific process parameters (e.g., high level, high temperature)
5. Vessel to permit partial removal of the process inventory in the event of a release (e.g., deinventory tank)
6. Curbing or diking to contain liquid releases
7. Redundant equipment and instrumentation (e.g., uninterruptible power supply for process control systems, backup firewater pump)
8. Atmospheric relief devices
1. Fire suppression and extinguishing systems
2. Deluge systems for specific equipment
3. Trained emergency response personnel
4. Personal protective equipm
ent (e.g., protective clothing, self-contained breathing apparatus)
5. Mobile fire fighting equipment
6. Blast-resistant buildings to help protect control systems and personnel
Five-Year Accident History
The BP Amoco Texas City Refinery has experienced five accidental releases within the past five years that meet the EPA RMP reporting requirements with respect to on-site property damage or on-site injuries. None of these accidents resulted in any off-site impact to the community. Each accidental release was fully investigated as described in the Prevention Program section, and action has been taken to prevent recurrences.
In April, 1999, one maintenance employee received treatment for second degree burns to his neck, ears, wrist, and arms as a result of a hydrogen flash fire while removing a relief valve from a vessel at the Isom process.
In October, 1996, during a shutdown of the Ultracracking process, a hydrogen leak from a furnace tube failure ignited. There were no injuries, bu
t the fire caused significant on-site property damage.
In November, 1996, during a shutdown of the Ultraformer No. 4 process, a natural gas leak from a line rupture ignited. There were no injuries, but the fire caused significant on-site property damage.
In February, 1997, one operator and seven contract workers received treatment for possible chemical inhalation burns as a result of hydrogen fluoride exposure from a failed pump seal at the Alky No. 3 process.
In January, 1998, an operator received a second-degree chemical burn to his nose when he inhaled hydrogen fluoride vapors while disconnecting a hose at the Alky No. 3 process.
EMERGENCY RESPONSE PROGRAM INFORMATION
The BP Amoco Texas City Refinery has its own emergency response teams that cover Fire Response, HAZMAT Response, and First Aid Response on a 24 hour basis. Each of these emergency response teams train regularly every month to maintain their readiness and preparedness to tackle any incident involving flammable or toxi
c chemicals handled by the refinery.
The BP Amoco Texas City Refinery maintains a written emergency response program, which is in place to protect worker and public safety, as well as the environment. The program consists of procedures for responding to a release of a regulated substance, including the possibility of a fire or explosion if the substance is flammable. The procedures address all aspects of emergency response, including proper first-aid and medical treatment for on-site exposures, evacuation plans and accounting for personnel after an on-site evacuation, notification to the local government emergency management agency, and on-site, post-incident cleanup and decontamination requirements.
In addition, the BP Amoco Texas City Refinery has procedures to address the ongoing maintenance, inspection, and testing of emergency response equipment, as well as, instructions that address the use of emergency response equipment. Employees receive training in these procedures as nece
ssary to perform their specific emergency response duties.
The emergency response program is updated when necessary based upon modifications made to refinery processes, or other refinery facilities. Updates or changes are administered through the MOC process, which includes informing and/or training affected personnel.
The overall emergency response program for the BP Amoco Texas City Refinery is coordinated with the Texas City/La Marque/Hitchcock Local Emergency Planning Committee (LEPC). This coordination includes periodic meetings of the committee, which includes local emergency response officials, local government officials, and petrochemical industry representatives. The BP Amoco Texas City Refinery maintains around-the-clock communications capability with appropriate LEPC officials and emergency response organizations (e.g., fire department). This communications link facilitates quick response to an incident, and provides a means of notifying the public of an incident, if nec
essary. In addition to periodic LEPC meetings, the BP Amoco Texas City Refinery conducts periodic emergency drills that involve the LEPC and emergency response organizations.
PLANNED CHANGES TO IMPROVE SAFETY
As publicly stated in our Health, Safety and Environmental (HSE) Policy, the BP Amoco Texas City Refinery will continue to strive to achieve our HSE policy of no accidents, no harm to people, and no damage to the environment.
In addition to resolving all PHA findings, some of which result in modifications to the process, the refinery has an ongoing program which evaluates a range of projects, modifications and work practice improvements aimed at enhancing the efficiency of the refinery operation. This program includes various health, safety and environmental improvements, which, in many instances, go beyond compliance and are entirely voluntary.
At the time of submitting this Risk Management Plan, the following activities are currently being implemented or under active considera
7 Revised process instrumentation and/or controls in the fluidized catalytic cracking
7 Hydrocarbon release detection systems
7 Improved spill control dikes in the tank farm
7 Revisions to personnel training programs
7 Revision of the policy on relief valve inspection, repair, and on-line testing
7 Review of process vessel overpressure protection
7 Revision of the policy on reverse flow protection